Privacy Policy

Last Amended for Enforcement: AUG 14, 2020

1 Introduction

2 Contact Information

3 About this policy

4 Your privacy rights

5 How we collect your personal data

6 What personal data do we collect from you?

7 What do we use your personal data for?

8 Sharing your personal data

9 Data retention and deletion

10 Links

11 Keeping your data safe

12 Children

13 Changes to this Privacy Policy

1. Introduction

At Spirit Hub, we have built a digital shopping and education experience that is safe and secure. We take your privacy and the handling of your personal data very seriously. We want to clearly and transparently explain how and why we gather, store, share and use your personal data and explain the ways that you can control when and how you choose to share your personal data.

2. Contact Information

If you need to contact us regarding this policy, you may use any of the following options.

By Mail:
SPIRIT HUB
Attn: Privacy
6428 N Ridgeway Lane
Lincolnwood, IL 60712

By Phone:
1-800-867-7704

By Email:
privacy@spirithub.com

3. About this policy

The information collected about you while using our mobile application, text programs, and/or website (the 'Spirit Hub Service') is subject to this privacy policy. By using the Spirit Hub Service in any capacity, you agree to be bound by the terms of this policy.

The following statement describes our privacy practices for all of the Internet and mobile websites owned or operated by BF IL, LLC (referred to herein as the “Company”, “Spirit Hub”, or “we”). It applies to all information that we collect through your use of any Spirit Hub Services or your purchase of any products sold by us, including information obtained through your use of mobile websites, text programs and mobile applications.

For California residents, you may have additional policy rights provided by the California Consumer Privacy Act (“CCPA”). See our addendum for CA Residents for more information.

For European Union residents and businesses, laws for General Data Protection Regulation (“GDPR”) apply.

4. Your privacy rights

We extend the following privacy rights to our users and customers. As summarized here, include:

Right to transparency and clear communication. We will use plain language to describe our policies and notify you when the policies have changed.
Right of access. You have the right to know the source of your data, how we use it, how we process it, why we process it, and how long we retain your data. You also have the right to be provided with your own data upon request.
Right to rectification. You have the right to correct any information related to your personal data that is incorrect.
Right to erasure (“right to be forgotten”). You have the option to request for deletion of your data.
Right to restriction of processing. You have the right to request that we temporarily or permanently stop processing your personal data.
Right to data portability. You have the right to request your own personal data and move it to another service in a machine-readable format.
Right to object. You have the right to object our processing of your data for a specified reason.
Right not to be subject to a decision based solely on automated processing. You have the right not to be subject to a decision made solely on automated data processing, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

5. How we collect your personal data

We collect personal information from you in the following ways.

Use of our service. When you browse our website or use our mobile application, data such as your physical location, IP Address, browsing path on the site, and products that you add to lists.
Registration. When you register for a profile on our site, you pass information to us directly that includes directly attributable personal information.
Purchase. By purchasing products on our site, you pass information to us directly that includes directly attributable personal information such as your name, address, age, phone number and email address.
From third parties. We will receive information from third parties, including advertisers and service providers that allow you to use the Spirit Hub Service. We will use this data where you have provided consent to those third parties or to Spirit Hub for its use or processing, or where Spirit Hub has a legitimate interest to use the personal data for providing you a service on the platform.

We use anonymised and aggregated information for various purposes, including improving the Spirit Hub Service, developing new features and functionality within the Spirit Hub Service, testing our IT systems, research, data analysis, creating marketing, and developing promotions.

6. What personal data do we collect from you?

The data we collect can be described in these separate categories.

Account Registration Data
- Consists of information that is collected at the time you voluntarily create an account on the Spirit Hub Service.
- Includes submitted information such as your email address.
- Includes information that is derived but not submitted from the interaction, such as the browser you use when signing up, your IP address, location, and browsing history on the Spirit Hub Service.
Service Usage Data
- Consists of information that is submitted actively and passively when using the website, including personal data and technical data.
- Includes submitted information such as the lists you create, cart information, chats you conduct with our staff and email correspondence that you have provided to us.
- Includes information that is derived but not submitted such as your IP address, location, browsing history on the Spirit Hub Service, age, time and date of use, video content watched, third party applications where you have submitted your data with consent to be used, and other technical data that is used to improve the Spirit Hub Service.
- Technical data such as your browser information, network connection, network speed, type of device, operating systems, URL information, and cookie data may be collected during your use of the site.
Voluntary Data
- Consists of information that is voluntarily provided to improve the experience that you have with the Spirit Hub Service.
- With your expressed consent, we may utilize precise location data from your device which may include GPS or Bluetooth location-aware functionality while using the Spirit Hub Service. This does not include your IP address.
Payment Data
- Consists of personal information that is critical for mailing you packages that contain alcohol, consumables, and other hard goods.
- Includes submitted information such as your name, address, email address, phone number, age, and credit card information.
- Includes information that is derived but not submitted such as your IP address, location, third party applications where you have submitted your data with consent to be used, and other technical data that is used to improve the Spirit Hub Service.
- Due to the nature of our business, we may be required by law to retain the payment and submitted information you provide to us for a period that is governed on a state or federal level.
- The exact information you submit to us may be different depending on the type of payment method used, as different credit card companies may utilize different data services.
Contest and Survey Data
- This personal data is used to allow you to sign up and participate in these types of promotions. The exact personal data collected will vary depending on the promotion.
Marketing Data
- This personal data is used to enable Spirit Hub and our partners and service providers to send you marketing communications via email, while using the Spirit Hub Service, or directly from a third party.

7. What do we use your personal data for?

When you use or interact with the Spirit Hub Service, we use a variety of technologies to process the personal data we collect about you for various reasons. The processing purposes are outlined here.

Processing Purpose	Legal Basis for Processing Purpose	Information Collected and Processed
To provide, personalize, and improve your experience with the Spirit Hub Service and other services and products provided by Spirit Hub.	Performance of a Contract	Account Registration Data Service Usage Data
To understand how you access and use the Spirit Hub Service to ensure technical functionality of the Spirit Hub Service, develop new products and services, and analyze your use of the Spirit Hub Service, including your interaction with applications, advertising, products, and services that are made available, linked to, or offered through the Spirit Hub Service.	Performance of a Contract	Account Registration Data Service Usage Data
To communicate with you for Spirit Hub Service-related purposes.	Performance of a Contract	Account Registration Data Service Usage Data
To process your payment to prevent or detect fraud including fraudulent payments and fraudulent use of the Spirit Hub Service.	Performance of a Contract Compliance with legal obligations	Payment Data Service Usage Data
>To prevent the use of our site by users who are not of legal drinking age.	Compliance with legal obligations	Account Registration Data Voluntary Data Payment Data
To communicate with you, either directly or through one of our partners, for marketing, research, participation in contests, surveys and sweepstakes or promotional purposes. This communication may be via emails, notifications, or other messages, consistent with any permissions you may have communicated to us (e.g., through your Account Settings page).	Consent	Contests and Surveys Data Marketing Data
To provide you with features, information, advertising, or other content which is based on your specific location.	Consent	Voluntary Data

Publicly available information

The following personal data will always be publicly available on the Spirit Hub Service: your name and/or username, profile picture and comments posted for the purpose of product reviews.

Personal data you may choose to share

Personal data will only be shared with the third party applications and devices you connect if:

you choose to make use of a specific Spirit Hub Service feature where sharing of particular personal data is required for the proper use of the Spirit Hub Service feature; or
you grant us your permission to share the personal data, e.g. by selecting the appropriate setting in the Spirit Hub Service or authorizing Spirit Hub through a presented consent mechanism.

Information we may share

Categories of Recipients	Reasons we may share
Service providers	We work with service providers that work on our behalf which may need access to certain personal data in order to provide their services to us. These companies include those we've hired to provide customer service support, operate the technical infrastructure that we need to provide the Spirit Hub Service, assist in protecting and securing our systems and services, and help market Spirit Hub’s own products and services as well as partner products, services, events, and co-branded promotions in which Spirit Hub is involved.
Payment processors	We will share your personal data with our payment processors as necessary to enable them to process your payments, and for anti-fraud purposes.
Advertising partners	We work with advertising partners to enable us to customize the advertising content you may receive on the Spirit Hub Service. These partners help us deliver more relevant ads and promotional messages to you, which may include interest based advertising (also known as online behavioral advertising), contextual advertising, and generic advertising on the Spirit Hub Service. We and our advertising partners may process certain personal data to help Spirit Hub understand your interests or preferences so that we can deliver advertisements that are more relevant to you.
Spirit Hub partners	Depending on how you sign up for the Spirit Hub Service (e.g. through a third party service or a mobile provider), we share your Spirit Hub username or other User Data as necessary to enable your account. We may also share personal data with that third party about your use of the Spirit Hub Service, such as whether and to what extent you have accepted an offer, activated a Spirit Hub account, or actively used the Spirit Hub Service.
Law enforcement and data protection authorities	We share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena. We also share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.
Purchasers of our business	We will share your personal data in those cases where we sell or negotiate to sell our business to a buyer or prospective buyer. In this situation, Spirit Hub will continue to ensure the confidentiality of your personal data and give you notice before your personal data is transferred to the buyer or becomes subject to a different privacy policy.

9. Data Retention and Deletion

We keep your personal data only as long as necessary to provide you with the Spirit Hub Service and for legitimate and essential business purposes, such as maintaining the performance of the Spirit Hub Service, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. We keep some of your personal data for as long as you are a user of the Spirit Hub Service. For example, we keep your shopping cart, viewing history, and account information.

If you request, we will delete or anonymize your personal data so that it no longer identifies you, unless we are legally allowed or required to maintain certain personal data, including situations such as the following:

If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;
Where we need to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,
Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.

10. Data Retention and Deletion

We may display advertisements from third parties and other content that links to third-party websites. We cannot control or be held responsible for third parties’ privacy practices and content. If you click on a third-party advertisement or link, please understand that you are leaving the Spirit Hub Service and any personal data you provide will not be covered by this Policy. Please read their privacy policies to find out how they collect and process your personal data.

11. Keeping your data safe

We are committed to protecting our users’ personal data. We implement appropriate technical and organizational measures to help protect the security of your personal data; however, please note that no system is ever completely secure. We have implemented various policies including pseudonymization, encryption, access, and retention policies to guard against unauthorized access and unnecessary retention of personal data in our systems.

Your password protects your user account, so we encourage you to use a strong password that is unique to your Spirit Hub account, never share your password with anyone, limit access to your computer and browser, and log out after having used the Spirit Hub Service.

12. Minors

The Spirit Hub Service is intended for only users of legal drinking age. We do not want to and do not knowingly collect any data from people under age 21. If we learn that we collected any such data, we will take all reasonable measures to delete that information and to not use it for any purpose (except where required or allowed by law). If you become aware of any personal information we have collected from minors under 21, please contact us at the addresses listed in Section 2. Contact Information. Please note that reasonable efforts will be made to comply with such requests, and we ask that identifying information be provided in order to fully identify the user.

13. Changes to this Privacy Policy

We may occasionally make changes to this Policy.

When we make material changes to this Policy, we’ll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Spirit Hub Service or by sending you an email and/or a device notification. We may notify you in advance.

Please, therefore, make sure you read any such notice carefully.